Ascensus Investment Advisors, LLC (“AIA” or the “Firm”) is a direct and wholly owned subsidiary of Ascensus Group, LLC. The majority ownership of Ascensus Group, LLC is Trident VIII, L.P. (“Trident”), an investment vehicle controlled by Stone Point Capital, LLC, a SEC registered investment adviser. As a result, Trident is the ultimate owner of AIA. AIA does not control any other firm. Please refer to the Firm’s Form ADV Part 1 available at www.adviserinfo.sec.gov for additional information on corporate structure. AIA was registered with the Securities and Exchange Commission (“SEC”) as an investment adviser with an effective date of September 27, 2002. AIA is also registered as a Municipal Advisor firm registered with the Municipal Securities Rulemaking Board (“MSRB”) with an effective date of September 9, 2014. AIA provides investment management, monitoring, and consulting services for the Government Savings and Retirement Plan business divisions within Ascensus Group, LLC as described below. Government Savings Division Within the Government Savings Division, AIA provides investment management services for (i) state government administered Qualified Tuition Plans, also known as 529 education savings plans pursuant IRS Section Code 5291 ; (ii) Qualified ABLE programs per IRS Section Code 529A pursuant to the Stephen Beck Jr., Achieving a Better Life Experience Act of 2014 (the “ABLE Act”)2; and (iii) State Facilitated Retirement Plans (“SFRP”) that are available to employers in certain states pursuant to state law who do not offer a qualified retirement plan to its employees. The 529 Plans, 529 ABLE Plans, and SFRP Plans are hereinafter referred collectively as the “Plans”. The 529 plan serves to exempt qualified educational expenses from federal income tax. The 529 ABLE plan serves to exempt qualified disability related expenses from federal income tax. Members of the general public, as participants, may seek to invest for certain educational and disability related expenses and obtain certain tax advantages, as available. Contributions are used to acquire units in a trust as authorized by state law, with trust assets invested in a manner consistent with the trust’s stated investment objectives and related Plan documents. These units constitute municipal fund securities3. Under current federal tax law, earnings from a 529 savings plan used for qualified education expenses of the designated beneficiary are excluded from gross income for federal income tax purposes. Each Plan is administered by a state sanctioned body or official such as a state treasurer’s office or state board of trustees (referred to as “State Administrators”) who are empowered by state statutes to administer the Plans and the assets therein. Each Plan provides important information including disclosure documents to current and potential participants and is available on the Plan website. SFRP plans are established pursuant to state law and require private sector employers that do not sponsor a retirement plan to allow employee payroll contributions to be placed in a state facilitated individual retirement account. Plan details may vary by state, but generally, employees are automatically enrolled in the state retirement program at a fixed contribution percentage that may increase over time, although employees can choose to opt out or change their contribution. Like 529 and 529 ABLE plans, SFRP plans are also administered by a State Administrator. Each Plan provides important information including disclosure documents to current and potential participants and is available on the Plan website. AIA carries out its responsibilities in accordance with the direction of the applicable State Administrator for each Plan as well as any restrictions as set forth within the applicable Plan’s offering document (“Program Description”) for the Plan of record. The Firm is also subject to the rules and regulations adopted by the applicable State Administrators and/or any other investment policies or directives that said State Administrators may establish or issue. Government Savings Division – Investment Management Services Investment Management Process: AIA’s advisory services are limited to providing non-discretionary investment-related services to municipal entity State Administrators. AIA’s clients do not include Plan participants. AIA typically provides two levels of service to State Administrators:
• Investment Oversight and Monitoring: AIA will monitor the underlying Plan investments held within the Plan trust and advise investment partners of quantitative and qualitative analyses of the underlying investment options. When applicable, AIA will provide reporting where the Firm believes the investment manager(s) or investment 1 IRS Section Code 529 can be found at Title 26, Subtitle A, Chapter 1, Subchapter F, Part VIII, Section 529 of the Internal Revenue Code (“IRC”). 2 IRS Section Code 529A can be found at Title 26, Subtitle A, Chapter 1, Subchapter F, Part VIII, Section 529 of the IRC. 3 MSRB Rule D-12 defines as a municipal security issued by an issuer that, but for the application of Section 2(b) of the Investment Company Act of 1940, would constitute an investment company within the meaning of Section 3 of the Investment Company Act of 1940. option(s) within the Plan lineup are not meeting expectations. AIA also makes non-discretionary recommendations to State Administrators and investment partners on the investment options as appropriate. It is ultimately up to the State Administrator what, if any, appropriate action to take.
• Comprehensive Investment Management Services: AIA is responsible for most aspects of managing the Plan’s underlying investments held in the Plan trust including investment manager search and selection recommendations, portfolio and glidepath construction, investment lineup formation, investment monitoring, and performance reporting. All underlying investments must be selected, monitored, and overseen in compliance with the applicable Plan’s investment policy. Ultimately, all investment decisions are made by the Plan’s State Administrators who are not bound to AIA’s recommendations. AIA advises State Administrators on underlying investment lineups contained with the Plan. A Plan’s investment lineup generally consists of one or more of the following options:
• Age-Based Options (529 Plans): An Age-Based investment lineup consists of a series of portfolios which are assigned to different beneficiary age bands. These portfolios become more conservative in allocation as the beneficiary ages and gets closer to education enrollment. The portfolios themselves remain static in terms of asset allocation with the participant moving from portfolio to portfolio as they age.
• Year of Enrollment (529 Plans): A year of enrollment portfolio allows the investor to select a targeted education enrollment year. In this option, the participant does not move from portfolio to portfolio. Rather, the portfolio’s asset allocation is automatically adjusted over time to hold more conservative investments as the targeted enrollment year approaches.
• Target Date Options (SFRP Plans): A target date portfolio allows the investor to select a targeted retirement year/age. In this option, the participant does not move from portfolio to portfolio. Rather, the portfolio’s asset allocation is automatically adjusted over time to hold more conservative investments as the targeted retirement age approaches.
• Individual Portfolios (529 and SFRP Plans): An individual portfolio allows the investor to choose one or more investments from a selection of investment options available in the Plan.
• Risk-Based Asset Allocation Portfolios (529 and 529 ABLE Plans): A blend of investments typically designed to match a defined risk tolerance such as Aggressive, Growth, Moderate, or Conservative. These allocation portfolios are static and only adjust their asset allocations to remain consistent with the stated target allocation and risk tolerance. The underlying investments contained within the investment portfolios or investment options can be a combination of securities that include mutual funds, exchange traded funds (ETFs), separately managed accounts, and insurance company products such as stable value accounts. Please refer to the applicable Plan disclosure document available on the Plan website for additional information on investment options available in each Plan. It is important to note that although a portfolio or investment option within the Plans may invest in a particular security or basket of securities held within the Plan trust, the Plan participant (i.e., account owner) does not own shares of that security. The investor owns municipal security units of the Plan’s investment portfolio which are calculated using net asset value, referred to as municipal fund securities. Manager Search and Selection: The State Administrator will create an investment policy statement (“IPS”) for the Plan, typically based on state statute requirements. AIA will work with the State Administrator and any investment partners to help design underlying investment options and make recommendations for appropriate underlying investments that will meet the Plan’s needs in accordance with the IPS. When selecting investment managers and underlying investment products, AIA utilizes a five-parameter research and evaluation process called PROVE. The five parameters are (i) Performance; (ii) Risk; (iii) Operations; (iv) Volatility; and (v) Expense. This process gives weight to the quantitative and qualitative metrics AIA considers when analyzing a fund or an investment process. The AIA Investment Management Department reviews the available mutual funds and ETFs quarterly for funds with greater than 5 years of performance history. The process uses different metrics for equity and fixed income products based on the strongest predictors of success. Each metric is measured against multiple time periods. The time periods are weighted to give more importance to metrics that are representative of both long-term and short-term track records. For example, a metric measured over 5 years would have more weight in the scoring process than a statistic that was only measured over 1 year (only showing short term), or a metric measured over 10 years (which may include results from economic conditions that do not exist today). While each metric holds a different weight in the overall score, each of the five parameters in PROVE holds an equal 20% weight. Through this process, the Investment Management Department develops a list comprised of the top 4-10 products in each category based upon its analysis. The list is used as a reference when recommending new investment lineups or underlying investments. Investment Monitoring and Oversight: The Investment Management Department will monitor the underlying investments in accordance with the AIA investment monitoring process. On a monthly basis, the Investment Management Department will (i) review the output of AIA’s monitoring process which includes the products contained within the Plans. The system codes the funds green or red (stop light methodology); and (ii) review and discuss any funds coded red; and (iii) makes a determination regarding the need to place any of those funds on a formal watch list. Funds are coded red when their performance falls outside their tolerance bands. For an actively managed fund, the tolerance band is a combination of the difference between the average return of its peer group and its primary benchmark. The tolerance also contains a floor (equity funds, 1.00% and fixed- income funds, 0.50%), and a ceiling (equity funds, 5.00% and fixed-income funds, 3.00%). Tolerances for passively managed funds allow for the funds to trail their appropriate benchmarks by their net expense ratios plus 0.15%. The length of time that a fund appears on a watch list will determine if it will be moved to the Action list. The Action list triggers a deeper analysis that requires AIA to further analyze the investment manager to understand the performance issues. If AIA is satisfied with the investment manager’s response, AIA will leave the fund/product

on the watch list. If AIA is unsatisfied with the investment manager’s response, AIA will discuss that particular product with the investment partner. In instances where AIA is unable to gain comfort concerning the product’s performance, AIA will bring it to the Firm’s Investment Management Committee and State Administrator’s attention for further review and discussion, as appropriate. If AIA is providing comprehensive investment services, AIA may recommend another investment to replace the current investment, as appropriate based on the investment management process. That decision will be based upon AIA’s assessment that another investment option better meets the needs of the Plan and the requirements of the investment policy. If AIA is providing investment oversight and monitoring only, AIA will review and suggest other investment options that may better meet the needs of the Plan and investment policy requirements, if appropriate. In all cases, the State Administrator will make final investment decisions and any trades will be executed by the Plan’s qualified custodian. AIA is wholly owned by Ascensus Group, LLC which is wholly owned by Ascensus Holdings, Inc. As of August 2, 2021, AIA is indirectly owned by Trident VIII, L.P. – the ultimate parent of Ascensus Holdings, Inc. – which is an investment vehicle of Stone Point Capital, LLC (CRD# 156521), a SEC registered investment adviser since March 2012. Please see AIA’s Form ADV Part 1 available on the SEC’s Investment Adviser Public Disclosure website, and Item 10 of this disclosure document for additional information regarding the Firm’s corporate structure. Retirement Savings Division Within the Ascensus Retirement Savings Division, AIA provides investment fiduciary services to ERISA covered 401(k) retirement plans through the Ascensus CoPilot retirement plan product offering (“CoPilot”). CoPilot is a simple, cost effective 401(k) retirement plan designed for small businesses. AIA provides investment advisory and other services for retirement plan sponsors (“Plan Sponsors”) on a non-discretionary basis as agreed upon by AIA and the client which are detailed in contractual agreements. For non-discretionary services, AIA will act solely in an advisory capacity and will not have or exercise any discretionary authority with respect to the assets of the plan. AIA serves as a fiduciary to the plan in providing the investment advisory services delineated in the agreement signed by the client and AIA. CoPilot Investment Fiduciary Services AIA provides the following investment fiduciary services as a registered investment adviser within CoPilot: i. Investment Policy Statement: Develop, review, and/or make recommended changes to an Investment Policy Statement (“IPS”) for CoPilot. A copy of the IPS will be periodically provided to plan sponsors for review. ii. Investment Manager Evaluation and Selection: Research, periodically evaluate, and select an ERISA 3(38) investment manager for CoPilot based on the criteria contained in the IPS. AIA will inform the Plan Sponsor of the ERISA 3(38) investment manager chosen, apprise Plan Sponsor of monitoring efforts, and forward any applicable analysis performed by the ERISA 3(38) investment manager to the Plan Sponsor by posting the analysis to the plan website. iii. Asset Allocation Tools: Make available to plan sponsors appropriate asset allocation tools for Participants, including model portfolios, rebalancing services, and/or a combination thereof, or other asset allocation tools or services. iv. Investment Direction: Plan Sponsor directs AIA to coordinate with the ERISA 3(38) investment manager to construct a plan investment lineup. v. Monitoring Investments: Monitor the quantitative and qualitative performance of each investment option in accordance with the investment guidelines set forth in the IPS. a. AIA will prepare a periodic written investment report reviewing the plan investment menu. b. The report will identify menu options falling below certain criteria established in the IPS for potential replacement and recommend replacement of any investment options to be discussed with the ERISA 3(38) investment manager. c. AIA will coordinate with the ERISA 3(38) investment manager to implement any of the ERISA 3(38) investment manager’s recommended modifications to the investment lineup and/or asset allocation tools for the Plan in line with the IPS. vi. Review and Oversight: Attend meetings when requested by the Plan Sponsor for the purpose of: (i) reviewing quarterly reports; (ii) providing Plan Sponsor representatives with an assessment of investment performance and recommendations for further consideration; and (iii) assisting the Plan Sponsor in addressing matters related to the investment menu and asset allocation tools. vii. SEC Form ADV Delivery: Provide a SEC Form ADV Part 2 to the Plan Sponsor. On an annual basis, AIA will deliver the Form ADV Part 2A and 2B or a summary of material changes. In addition, AIA will deliver its brochures where more frequent delivery is required by applicable law. viii. Proxy Voting: Review and vote applicable proxies with respect to securities held in the Custodial Account and other reports to stockholders provided by any issuer. CoPilot Preparation of Investment Policy Statement: AIA assists CoPilot clients in preparing the investment policy statement (“IPS”), including investment objectives, policies, and constraints consistent with the plan’s requirements. It is important to note that AIA is not responsible for investment decisions made by plan participants. AIA also is not responsible for investment decisions involving employer securities or for plan assets that have not been designated as subject to AIA’s authority as an investment advisor. CoPilot Performance Monitoring and Reporting: AIA monitor the plan’s investment manager(s) and investments and may recommend additional investments and investment managers or other changes from time to time in coordination with the 3(38) investment manager. AIA will recommend appropriate action, when necessary, that may include replacing an investment or investment manager. CoPilot Participant Education When requested by the CoPilot plan participant, AIA will provide general information and education to the plan participant as to the features of the plan and the available investment options in order to assist them in selecting the model allocation that best meets their needs. AIA does not provide individualized investment advice to plan participants. AIA will monitor the investment elections and allocation changes of plan participants and will attempt to notify participants who are investing in a manner that is materially different from the default investment allocation they would otherwise be subject to in an effort to educate participants on the options available to them. Assets Under Management and Assets Under Advisement: Government Savings Division As of December 31, 2023, AIA provided non-discretionary advisory services to forty-three (43) state administered Plans with approximately $101,933,116,363 in Plan assets, as described below: Regulatory Assets Under Management $9,878,077,323 Assets Under Advisement $92,055,039,039 Retirement Savings Division As of December 31, 2023, AIA provided investment advisory services for approximately $1,200,587,8744 in total CoPilot assets as described below: Regulatory Assets Under Management $0 Assets Under Advisement $1,200,587,874 Conflicts of Interest Investment advisers are fiduciaries that have a fundamental obligation to act in the best interest of their clients and to provide investment advice in their clients’ best interest. AIA, like all financial service providers, has conflicts of interests. A conflict of interest may exist where AIA and/or its personnel have the opportunity to benefit in contrast to a client’s best interests. These conflicts could be actual, potential, or perceived. It is important to note that the Firm discloses, manages, and mitigates its conflicts of interest, and if the conflict is unable to meet these requirements, the Firm does not engage in that activity. Services of Affiliated Entities of AIA AIA is a subsidiary of Ascensus Group, LLC. A such, AIA typically provides investment advisory services in tandem with, or as part of, an entire service offering along with its industry affiliates. As a result, other firms may offer products and services that are not available through AIA, or the same or similar services at a different or lower cost. Gifts, Gratuities, Entertainment, & Non-Cash Compensation AIA Associates may generally give and receive business related gifts, gratuities, and entertainment, so long as such gifts and entertainment are (i) within Firm policy; (ii) not lavish or excessive; and (iii) do not give the appearance of being designed to influence the recipient or otherwise create a material conflict of interest. AIA Associates are required to disclose to the Firm any business related gifts, gratuities, entertainment, and non-cash compensation given or received. Political Activities and Pay to Play The SEC, Municipal Securities Rulemaking Board (“MSRB”) and other regulatory authorities have specific rules regarding political contributions and other related political campaign activities. The phrase “pay-to-play” refers to a payer (e.g., individual, business, or organization) who makes campaign contributions to public officials or candidates, party officials, political action committees (PACs), or parties themselves, and receives a real or perceived political or pecuniary benefit. As a result, Firm policy limits AIA Associates ability to engage in political contributions and other campaign activities. Political contributions should be reviewed by the Firm prior to being made so as to assure they are made in accordance with applicable rules and Firm policy. Revenue Sharing Arrangements Certain revenue sharing contractual arrangements with AIA and its affiliates include the payment of additional fees by certain underlying investments or investment management firms available within a Plan. These fees are based on the value of the assets in the underlying investment. Please refer to Item 5 of this brochure as well as the Plan’s offering document for more information on these arrangements. Limitations on Investment Recommendations AIA offers and recommends investment products only from investment sponsors with which the Firm has entered into selling, distribution, or operational agreement as well as meeting the Firm’s due diligence processes per fiduciary obligations. As a result, other firms may offer products and services that are not available through AIA, or the same or similar investment products and services at a different or lower cost. 4 CoPilot with AIA services launched in September 2023 AIA Associates Outside Business Activities AIA Associates who are IARs and seek to engage in certain (non-AIA or Ascensus related) outside business activities (OBAs) are required to disclose and obtain approval from the Firm. Generally, if the OBA presents a material conflict of interest in the services provided by AIA to its clients it may be limited or prohibited. Please refer to the ADV Part 2B brochure supplement for additional information. AIA Associates Personal Securities Transactions AIA has adopted a code of ethics that includes guidelines regarding personal securities transactions of its employees and IARs. The code of ethics permits employees and IARs to invest for their own personal accounts in the same securities that the Firm recommends for clients. The Firm addresses this conflict of interest by requiring in its code of ethics that employees and IARs report applicable personal securities transactions and holdings to AIA for review. The AIA Code of Ethics is available upon request. Contracts AIA enters into written agreements with its clients prior to engaging in any advisory services. All contracts must be in writing and typically includes a package of services that AIA and its affiliated entities engage in to provide various services to the Plans. AIA may also enter into agreements with its investment management partners in the form of sub-adviser contracts and operating agreements in order to provide services to its clients, as AIA does not offer proprietary securities products.